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Commissioner of Income Tax (International Taxation-1), New Delhi vs Deloitte Touche Tohmatsu – Doctrine of Mutuality Excludes Subscription Receipts from Taxation (Section 260A, Income Tax Act)
Facts of the
CaseThe respondent/assessee, Deloitte Touche Tohmatsu,
is an association (Verein) established in Switzerland comprising member firms
(chartered accountant entities) across the globe.For Assessment Years 2...
Commissioner of Income Tax, International Taxation–1, New Delhi vs Deloitte Touche Tohmatsu (Delhi High Court) – Mutuality Principle & Taxability of Subscription Receipts under Income Tax Act
Facts of the
Case
The assessee, Deloitte Touche Tohmatsu, is a Swiss Verein
(association) consisting of member firms across the globe.
It filed income tax returns for AY 2008–09 to AY 2011–12 declaring ni...
Commissioner of Income Tax (International Taxation)-1, New Delhi vs Deloitte Touche Tohmatsu | Section 260A | Doctrine of Mutuality | Whether Subscription Receipts Constitute Fees for Technical Services
Facts of the CaseThe respondent assessee, Deloitte Touche Tohmatsu
(Verein), is an association established in Switzerland comprising member firms
across the globe engaged in professional services such as audit, account...
Principal Commissioner of Income Tax-7 vs M/s Pilot Industries Ltd. (Delhi High Court) – Appeal Dismissed as Covered by Earlier Judgments for AY 2010–11
Facts of the
Case
The present appeal was filed by the Revenue concerning Assessment
Year (AY) 2010–11.
The appeal challenged the order dated 23.11.2021 passed by the
Income Tax Appellate Tribunal (ITA...
Pr. Commissioner of Income Tax (Central)-2 vs. Electrical and Electronics India Ltd. | Delhi High Court | Section 69 Income Tax Act | AY 2011-12
Facts of the
Case
The case relates to Assessment Year 2011–12.
The Assessing Officer made an addition of ₹4,25,00,085 under
Section 69 alleging unexplained investments by the assessee in the
JP Mind...
Rishi Ganga Power Corporation Ltd. vs Assistant Commissioner of Income Tax (Delhi High Court, 2023) – Effect of Approved Resolution Plan on Income Tax Demands under IBC
Facts of the
Case
The petitioner, Rishi Ganga Power Corporation Ltd. (RGPCL),
filed its return for AY 2017–18 declaring losses.
During assessment, the Income Tax Department:
Passed an order under Sec...
Tata Steel Limited vs Deputy Commissioner of Income Tax (Delhi High Court, 2023) – Pre-Resolution Tax Dues Extinguished under IBC Clean Slate Principle
Facts of the
CaseThe petitioner, Tata Steel
Limited (TSL), challenged a notice dated 28.08.2018 and order dated 17.10.2018
issued by the Income Tax Department under Section 221(1) of the Income Tax Act
demanding tax ...
ANURADHA BAKSHI vs PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL NEW DELHI–1 (Delhi High Court, 2023) – Limitation under Sections 153A, 153B & Revision under Section 263 of Income Tax Act
Facts of the
CaseThe petitioner, Anuradha Bakshi, an
entrepreneur engaged in apparel design and consultancy, was subjected to a
search and seizure operation under Section 132 of the Income Tax Act, 1961
in March 2021...
Principal Commissioner of Income Tax-07, Delhi vs M/s Pilot Industries Ltd. (Delhi High Court) – Appeal Dismissed as Covered by Earlier Judgment (AY 2011-12)
Facts of the
CaseThe appeal was filed by the Revenue (Principal
Commissioner of Income Tax-07, Delhi) challenging the order dated 23.11.2021
passed by the Income Tax Appellate Tribunal concerning Assessment Year 2011â...
PR. Commissioner of Income Tax-4, New Delhi vs Indus Towers Ltd. | Delhi High Court | Section 36, 37, 32, 43B, 260A Income Tax Act | Interest, Depreciation & Loan Processing Fee Deduction Case
Facts of the
CaseThe respondent/assessee, Indus Towers Ltd.,
a public limited company, was incorporated as a joint venture of telecom
entities to provide shared telecom infrastructure services. It filed its return
de...